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Don't Put Discovery Disputes on the Back Burner

It's never a good idea to put discovery disputes on the back burner. Even so, it's always tempting: not only can discovery disputes be tedious and boring, but they can also make you miserable, especially when you have to butt heads with your opponent.

It helps if you can train yourself to address discovery disputes as soon as possible without turning them into a battle of personalities. When your opponent is late with responses, send a letter, make a phone call, and then file a motion to compel. When your opponent tries to dodge your discovery with improper objections, don't let the objections get buried on your desk. Try to work them out. If that's not possible, file a motion.